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On June 18, FinCEN’s Associate Director for Enforcement, Stephanie Brooker, delivered remarks at the Bank Secrecy Act Conference, focusing on three main areas: (i) BSA filing trends, the value of BSA data, and compliance development in the casino industry over the past year; (ii) FinCEN’s enforcement approach and recent enforcement developments; and (iii) the significance of establishing and maintaining a culture of compliance throughout the business and compliance sides of casinos and card clubs. In addition, Brooker noted certain principles at the core of FinCEN’s enforcement program: (i) transparency in the agency’s rationale behind its enforcement actions; (ii) accountability, ensuring that financial institutions, and any individual related to the financial institution, take responsibility for violations of the BSA; and (iii) giving credit where credit is due by considering an institution’s “documented improvements in AML compliance over time.” Finally, Brooker stressed that in order for a financial institution to successfully maintain a culture of compliance, its business side and business leaders must take AML controls and BSA compliance seriously, meaning that “every casino employee, from the top down, views AML compliance as part of his or her responsibility.”

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